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Rostrum Investments & Securities Limited

Best Execution Policy

BEST EXECUTION POLICY AND PROCEDURES

INTRODUCTION

Best Execution Policy is a policy adopted by Rostrum Investment and Securities Limited to obtain the best possible result for its clients, taking into account price, costs, speed, likelihood of execution and settelement, size, nature and/or any other relevant order execution consideration.

We are required to have in place a Best Execution Policy and take all reasonable steps to obtain the best possible result for our clients when executing, receiving and transmitting client orders.

Scope

Our best execution policy will apply whenever will receive order directly from a retail client or wholesale client for execution on their client's behalf. This policy will apply when an order is placed by a client via the required buy or sell mandates.

BEST EXECUTION PROCEDURES

a) When we receive a client's order

When we receive, transmit or execute orders in relation to equity market products on the client's behalf, we will take all reasonable steps to achieve Best Execution.
An order may be received in several ways:

  • Via email
  • Telephone
  • In person through duly signed mandates

b) Executing client orders

We will generally give price a higher relative importance when obtaining the best possible outcome for orders executed on client's behalf. However, depending on the type of clients (Wholesale or Retail). We may also take into consideration a range of different factors, including the following:

  • The need for timely execution
  • Availability of price improvments
  • The liquidity of the market (which may make it difficult to execute an order)
  • Price of the equity market product
  • Speed of processing
  • Likelihood of execution and settlement
  • Potentila price impact

Execution certainty, the size of the order and the nature of the financial transaction including whether or not such transactions are executable on a regulated market are also considered.

c) Transmitting of client orders

All orders that Rostrum Investment and Securities Limited receives from its clients are transmitted to the X-Gen of NSE and are executed in a manner where we will take all reasonable steps to achieve Best Execution, in accordance with this policy, taking account of the factors noted above at b) (if applicable) and any specific instructions received from you as part of the order, as applicable.

d) Best outcome for a Retail Client

For a Retail Client the best outcome means the best Total Consideration (unless the Retail Client has given Rostrum Investment and Securities Limited a specific instruction). To ensure Best Execution of retail clients’ orders, Rostrum Investment and Securities Limited uses analytical tools to identify the extent that better execution was available on markets other than the market of execution.

e) Best outcome for a Wholesale Client

For a Wholesale Client the best outcome may occur as a result of price, costs, total consideration, speed, likelihood of execution or any other relevant factor, or any combination of those factors.

It may also occur as a result of Rostrum Investment and Securities Limited following a specific or standing instruction that have been provided.

Best Execution will be achieved in accordance with this policy and is designed to obtain on a consistent basis the best possible result for execution of your orders, subject to and taking into account the nature of your orders, the priorities you place upon us in filling those orders and the nature of relevant markets.

SPECIFIC INSTRUCTIONS

To the extent the client provide us with specific instructions in relation to their order or any part of it, Rostrum Investment and Securities Limited will act on the client’s instructions and, in doing so, the client may not necessarily receive the best outcome in relation to Best Execution.

If the client requires their order to be executed in a particular manner (i.e. limit order), the instructions must clearly state the desired method of execution when the order is received. If the client or the client’s financial adviser gives an order verbally (i.e. by telephone) Rostrum Investment and Securities Limited’s preferred method of being contacted, we must record those instructions. A client can provide their specific instructions in writing.

When a client provides us with a specific instruction as to the execution of an order that cannot be carried out in accordance with our Best Execution Policy, our Best Execution Policy will not apply and we will execute your order in accordance with your specific instructions.

A Retail Client cannot give us standing instructions for all of his/her orders.

If a Wholesale Client give us standing instructions for all of his/her orders, we will periodically review them to ensure they remain appropriate for them.

MONITORING AND REVIEW

We will monitor the effectiveness of our Best Execution policy and arrangements to identify and, where appropriate, correct any deficiencies. Rostrum Investment and Securities Limited maintains Complaints Management Registers where any issue relating to Best Execution or breach of the relevant legislation is recorded.

The Compliance Officer will have day to day supervision of the Policy and will review the controls in place and report each month. The Compliance and Risk Unit will perform independent control testing as part of their overall responsibilities. The reviews are documented and given to the Risk and Compliance Committee for review and recommendation of changes to the Policy and related Procedures.

We will carry out an annual review where there has been no change in the intervening 12-month period. Whenever a material change occurs that affects Rostrum Investment and Securities Limited’s ability to obtain the best result for its clients it will notify its clients of these changes via its website or in some cases, by email or direct mail.